EU to unify SUPD and PPWR with broader definition of ‘recycling’

The European Union has two major policies concerning single-use plastic beverage bottles: the Single-Use Plastics Directive (SUPD) and the Packaging and Packaging Waste Directive (PPWR).

The SUPD entered into force in July 2021; the PPWR became law in February 2025.

The SUPD sets recycled content targets for PET bottles of at least 25% by 2025 and of 30% for all single-use plastic beverage bottles by 2030. The PPWR also sets a 30% recycled content target for all single-use plastic beverage bottles by 2030.

The Commission Implementing Decision (EU) 2023/2683 of November 2023 implements rules for the application of the SUPD. According to that act, the 25% target for PET ‘can only be achieved using post-consumer plastic waste generated from plastic products that have been placed in the EU market,’ a spokesperson for the European Commission told Sustainable Plastics. That confirms that plastic waste from outside the EU cannot currently count towards SUPD targets.

The PPWR, on the other hand, allows for post-consumer plastic waste from outside the EU to count towards its targets, under some conditions.

Paragraphs 3(a) and 3(b) of article 7 set out the PPWR’s controversial ‘mirror clause’. This clause states that if imported plastic is to count towards meeting the PPWR’s recycling content targets, it must be collected in line with EU standards for separate collection and then processed in facilities that comply with the same pollution and emissions limits that apply to domestic producers.

The SUPD and the PPWR are thus not in line when it comes to waste feedstock.

Moreover, the PPWR’s definition of ‘recycling’ refers back to Directive 2008/98/EC, which leaves the legal status of chemical recycling uncertain, particularly for pyrolysis. The SUPD, on the other hand, is explicit in only recognising mechanically recycled material as counting towards its targets.

A spokesperson told Sustainable Plastics that the European Commission is preparing an implementing act that ‘will extend the calculation, verification, and reporting methodology to cover all recycling technologies, including chemical recycling’. That act will repeal and replace the existing one, aligning the SUPD and the PPWR.

The broader definition of ‘recycled plastic’ will cover recyclates made from post-consumer plastic waste placed on markets outside the EU.

The implementation act is expected in the fourth quarter of 2025. It will also have its say on accounting methodologies like mass balance, critical to chemical recycling technologies like pyrolysis. Previous reports suggest that a ‘vast majority’ of EU member states are in favour of adopting a fuel-exempt mass balance approach.

In mass balance, a certified volume of renewable or recycled material is input across a production run but may not be evenly distributed across each individual product output.

Using the mass balance method allows economic operators to state that they use a certain percentage of recycled or renewable material in their products, without having to prove that each individual product produced has that percentage of recycled or renewable material.

Given that pyrolysis oil is blended with virgin feedstocks in a cracker, and that the two feedstocks cannot be physically separated once co-fed, many argue that recognising mass balance is essential for allocating recycled content via this chemical recycling technology. 

source: Sustainable Plastics